Notice of Privacy Practices

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

This wording is required by federal regulation. 45 CFR §164.520(b)(1)(ii)

This notice applies to Alexander Seto Therapy, LLC and to Alexander Seto, DMFT, LMFT. It describes what I do with information about your health and your care, what I will not do with it, and what you can require of me.

It is longer than either of us would like. That is because federal law specifies much of what has to be in it. If any part is unclear, ask me and I will explain it in plain terms.

My commitments to you

• I will keep your health information private, and protect it in writing, on screen, and in conversation. 45 CFR §164.530(c)
• I will give you this notice and follow the version currently in effect. 45 CFR §164.520(b)(1)(v)
• I will tell you if your unsecured health information is ever breached. 45 CFR §§164.400–414
• When I use or share your information, I will limit it to the minimum needed for the purpose — except when I am giving it to you, sharing it for your treatment, or you have authorized it. 45 CFR §§164.502(b), 164.514(d)
• Where Hawaiʻi law protects your information more strictly than federal law does, I follow Hawaiʻi law. 45 CFR §160.203(b); HRS §334-5

How I may use and share your information without asking you first

Federal law permits the three uses below without your written authorization. In a solo telehealth practice most of them come up rarely. 45 CFR §164.506

Treatment

To provide and coordinate your care. For example, if you ask me to speak with your physician about how your medication is affecting your sleep, or to consult a previous therapist about what has already been tried.

45 CFR §164.506(c)(1)–(2). In practice I obtain your written authorization before contacting another provider, even where the law would not require it. AAMFT 2.2

Payment

To be paid for your care. Billing your insurer or an EAP requires me to send at minimum a diagnosis, the dates you were seen, and service codes. Some plans require more, including treatment plans or records, before they will authorize or pay. 45 CFR §164.506(c)(3)

Health care operations

To run the practice — reviewing my own work, arranging professional consultation, and managing business functions. When I consult a colleague about a case, I limit identifying information, and the colleague is bound by the same confidentiality I am. 45 CFR §164.506(c)(1); AAMFT 2.8

People and companies that work with me

Some services I rely on — my electronic record system, my payment processor, my email provider, my video platform — necessarily touch your information. Each is bound by a written agreement requiring them to protect it to the same standard I do. 45 CFR §§164.502(e), 164.504(e)

Uses and disclosures the law requires or permits

These are the circumstances in which I may or must share information without your authorization. Most will never apply to you. Where I have a choice, I disclose the minimum necessary and tell you first whenever I can.

• When required by law. Where a federal, state, or local law compels disclosure, I comply, and only to the extent the law requires. 45 CFR §164.512(a)
• Suspected child abuse or neglect. If I have reason to believe a child has been abused or neglected, or is at substantial risk, I must report it immediately to the Department of Human Services or the police, with a written report to follow. 45 CFR §164.512(b)(1)(ii); HRS §350-1.1
• Abuse of a vulnerable adult. If I know or have reason to believe a vulnerable adult has been abused or is in danger of abuse, I must report it promptly to the Department of Human Services. 45 CFR §164.512(c); HRS §§346-222, 346-224
• Serious threat to health or safety. If you present a serious and imminent danger to yourself, or communicate a serious threat of violence against an identifiable person, I may disclose what is necessary to prevent harm — which can include contacting the people you named as emergency contacts, emergency services, an intended victim, or law enforcement. 45 CFR §164.512(j); Hawaiʻi Rules of Evidence Rule 504.1(d)(6)
• Court orders and subpoenas. If a court orders release of your records, I comply. If I receive a subpoena, my first step is to assert therapist-client privilege on your behalf and, where appropriate, ask the court to limit or quash it. 45 CFR §164.512(e); Hawaiʻi Rules of Evidence Rule 504.1
• Health oversight. To agencies overseeing licensure, audits, investigations, and compliance — including the Hawaiʻi licensing board and the Regulated Industries Complaints Office. 45 CFR §164.512(d)
• Law enforcement. In the narrow circumstances federal law specifies, such as a valid court order or a legally required report. 45 CFR §164.512(f)
• Public health activities. To authorities responsible for preventing disease, injury, or disability. 45 CFR §164.512(b)
• Workers’ compensation. As authorized by workers’ compensation law, if you file a claim connected to your care. 45 CFR §164.512(l)
• Coroners, medical examiners, and funeral directors. As necessary for them to carry out their duties. 45 CFR §164.512(g)
• Research. Only under an approved protocol with privacy protections in place, or with your authorization. I do not currently use client records for research. 45 CFR §164.512(i)
• Specialized government functions. Limited military, national security, and correctional circumstances. 45 CFR §164.512(k)
• Health plan and insurance operations. Where you have authorized billing, as described above. 45 CFR §164.506(c)(3)

Information with extra protection

Psychotherapy notes

Psychotherapy notes are my private working notes about what happens in a session: impressions, questions, things I want to return to later. They are kept separate from the rest of your record. They are not sent to insurers, and they are not included when your records are released to anyone else.

The law protects them more strictly than the rest of your file. Three things follow from that:

• A general release does not reach them. If you sign a release so that I can speak with your physician, that release does not cover these notes.
• Releasing them takes a separate written authorization that applies to the psychotherapy notes and to nothing else. It cannot be bundled with any other permission you give me.
• I cannot make your treatment depend on signing it. If you decline, your care here continues exactly as before.

There are a few narrow exceptions where the law permits or requires disclosure without your authorization — for example, if you brought a legal proceeding against me and I had to defend myself, or where a law compels the disclosure.

One practical note. When someone requests your records, a written summary of your treatment usually answers the question better than these notes would, and reveals far less. Ask me if you are unsure which you need.

45 CFR §§164.501, 164.508(a)(2), 164.508(b)(4)(ii)

Mental health records under Hawaiʻi law

Hawaiʻi places its own restrictions on the disclosure of mental health records, separate from federal law. Where those restrictions are stricter, they control. HRS §334-5; 45 CFR §160.203(b)

Uses that always require your written authorization

• Marketing. I will not use your information to market anything to you without your written authorization. 45 CFR §164.508(a)(3)
• Sale of your information. I will never sell your health information. Any sale would require your authorization. 45 CFR §164.508(a)(4)
• Psychotherapy notes, as described above. 45 CFR §164.508(a)(2)
• Anything else not described in this notice. Any other use or disclosure requires your written authorization, which you may revoke in writing at any time. Revoking it stops future disclosures but cannot undo one already made. 45 CFR §164.508(a)(1), (b)(5)

Your rights

These are things you can require of me. Requests should be in writing. I will respond within the timeframes federal law sets, and I will tell you in writing if I deny a request and why.

See and get a copy of your record

You may inspect and obtain a copy of the information I use to make decisions about your care, including an electronic copy if I hold it electronically. I may charge a reasonable, cost-based fee for copying. Psychotherapy notes are the exception — access to those is at my discretion, and I will discuss alternatives such as a written summary. 45 CFR §164.524; AAMFT 2.3

Restrict what goes to your health plan when you pay privately

If you pay for a service in full, out of pocket, you may require me not to disclose that service to your health plan. I must honor this. It is the most concrete privacy tool in this notice, and it is worth knowing you have it. 45 CFR §164.522(a)(1)(vi)

Ask me to restrict other uses and disclosures

You may ask me to limit what I use or share for treatment, payment, or operations, or what I share with someone involved in your care. I am not required to agree, but if I do agree, I am bound by it. 45 CFR §164.522(a)

Ask to be contacted a particular way

You may ask me to reach you only at a certain number, only by email, or only at a certain address. I will accommodate reasonable requests and will not ask you why. 45 CFR §164.522(b)

Ask me to correct your record

If you believe something in your record is wrong or incomplete, you may ask me to amend it. If I deny the request, you may submit a written statement of disagreement, which becomes part of your record and goes out with any future disclosure of the disputed information. 45 CFR §164.526

Get a list of disclosures

You may request an accounting of certain disclosures I have made in the six years before your request. It excludes disclosures for treatment, payment, and operations, and those you authorized. 45 CFR §164.528

Get a paper copy of this notice

You may request a paper copy at any time, even if you agreed to receive it electronically. 45 CFR §164.520(c)(2)(iii)

Be told about a breach

If your unsecured health information is breached, I will notify you as federal law requires. 45 CFR §§164.400–414

Choose someone to act for you

Someone with legal authority to make health care decisions for you — a guardian, or an agent under a health care power of attorney — may exercise these rights on your behalf. I will verify that authority before acting on it. 45 CFR §164.502(g)

My duties, and how this notice can change

• I am required by law to keep your health information private, to give you this notice, and to abide by the version currently in effect. 45 CFR §164.520(b)(1)(v)(A)
• I reserve the right to change this notice, and to make the changed notice apply to information I already hold as well as information I receive later. 45 CFR §164.520(b)(1)(v)(C)
• If I make a material change, I will not put it into effect before the revised notice’s effective date. A current copy is available to you on request. 45 CFR §164.520(c)(2)(iv)
• How long I keep records: at least seven years after the last entry, with basic information preserved for twenty-five years. Some health plans require longer, and where they do the longer period applies. HRS §622-58
• If I die or become unable to practice, arrangements are in place for your records to be stored, transferred, or disposed of properly, and for you to be told how to reach them. AAMFT 2.7

Questions and complaints

If you have a question about this notice, or think your privacy rights have been violated, tell me first if you are comfortable doing so. I would rather hear it directly and fix it.

You may also complain to any of the following. No one at this practice will retaliate against you for filing a complaint, and your care will not be affected. 45 CFR §§164.520(b)(1)(vi), 164.530(g); 160.306

• Alexander Seto, DMFT, LMFT — Privacy Officer. (808) 520-1802 · privacy@alexandersetotherapy.com
• U.S. Department of Health and Human Services, Office for Civil Rights. Complaints may be filed online, by mail, or by email, and must generally be filed within 180 days.
• Hawaiʻi Regulated Industries Complaints Office (RICO), which investigates complaints against licensed marriage and family therapists for the state licensing board.
• The American Association for Marriage and Family Therapy, whose Code of Ethics I am bound by as a member.

Effective date: August 15, 2026. As stated above, this notice is subject to change: I reserve the right to revise it and to apply the revised version to information I already hold. The version posted on this page is the one currently in effect, and you may request a paper copy at any time.
Alexander Seto Therapy, LLC · Alexander Seto, DMFT, LMFT · Hawaiʻi License MFT-932